Note:

If the parties fail to resolve any issue in FTS, the taxpayer retains the option of requesting that the issue be heard through the traditional Appeals process.

If applicable, the IRS will report a proposed resolution reached as a result of EO FTS to the Joint Committee on Taxation in accordance with IRC 6405.

The IRS may reconsider a proposed settlement, as reflected in a signed FTS Session Report, upon receipt of comments on the proposed settlement from the Joint Committee on Taxation.

If the taxpayer declines to agree with any changes by the IRS upon reconsideration, close the case unagreed, and the taxpayer will retain all the usual rights to request Appeals consideration of any unagreed issues.